Independence is in the eye of the taxpayer

Royal Coat of Arms

Royal Coat of Arms

Lately, I’ve been seeing a lot more of this fellow making an appearance in various guises – the Royal Coat of Arms, also known as the HM Government crest. It’s on the government’s new one-channel website – It’s on the Department for Education’s website. It’s been spotted out and about.  So what’s going on?

It would appear that all government departments are adopting the same logo. This isn’t exactly news – the Telegraph ran a story about it a little while ago  which was almost certainly sourced from Simon Dickson’s excellent Puffbox blog. And the idea isn’t new either – back as far as 2009 various voices were already suggesting that it would be a good idea.

On the whole, I think this is a great idea for government departments, on a number of fronts.  If we think about the government’s corporate identity from the point of view of its audience (and really, is there any other way of considering it?), the taxpayer is not the slightest bit interested in which department does what. As a citizen, I want to interact quickly, efficiently and effectively with the government. I need information and I need access to services. I don’t want to think about why the Department for Children, Schools and Families (as it used to be called) has a rainbow for its logo.

Also from a taxpayer’s point of view, a unified corporate identity keeps costs down. No more money spent on rebrands, along with the associated costs of changing everything from stationery to signage. It’s utilitarian, it’s functional, and it works. This approach fits with the one government website recommended by Martha Lane Fox.

But. (There’s always a but.) I have a concern about the same rules being applied to some executive agencies – or more specifically, non-departmental public bodies (NDPBs).

To understand this concern, it’s important to understand the role NDPBs play in the public sector. An NDPB is defined as “a body which has a role in the processes of national Government, but is not a Government Department or part of one, and which accordingly operates to a greater or lesser extent at arm’s length from Ministers”. Clear as mud.

NDPBs are often set up by a Statute and (stay with me, this is important) they are accountable to Parliament, not the Government. This accountability comes via Ministers in their sponsor department (such as the Department for the Environment, Food and Rural Affairs or Department of Health) but the organisations remain at arm’s length, which is why they’re also known as Arm’s Length Bodies.

The reason for setting up these organisations is to provide independent advice and technical expertise to government, and/or to regulate important issues such as pollution or health and safety practice. Examples of NDPBs (there are hundreds) include Natural England, the Environment Agency, and the Health and Safety Executive.

The crucial word for me in that paragraph is independent. There are times when a government, or a local council, or a business, might want to do something specific. Build a new housing development, for example. These organisations exist to provide independent, trusted advice on whether it’s a good idea, from a very specific point of view. For example, the Environment Agency might advise on whether that particular housing development would be at risk of flooding (very topical), or the Health and Safety Executive might advise the developers how to run their construction site without putting their employees at risk. This kind of advice clearly exists outside policy remits – it’s about hard, factual evidence and expertise with no political bias or agenda. In the coalition government’s infamous Bonfire of the Quangos, Francis Maude reiterated this: “we recognise that some of these bodies do hugely important and essential work that has to be done at arm’s length from government, especially when political impartiality, independence or technical expertise is required.

So what does this have to do with brand and corporate identity? The answer is that I think this illustrates the difference between corporate identity and brand. If we just consider the unified identity from a corporate identity point of view, then where’s the harm in NDPBs adopting it? They do, after all, have a role in the processes of government. Shouldn’t they carry the government logo? After all, the name and the organisation would still be the same.

Corporate identity and brand are very different. Corporate identity is the logo, colours, fonts an organisation uses to badge itself. It’s the visual expression of the brand. But brand is so much more than just the corporate identity. To steal a rather neat definition from the Design Council, a brand is “a set of associations that a person (or group of people) makes with a company, product, service, individual or organisation.

Brand is about how that organisation makes you feel. An organisation expresses its brand in everything that it does – how its staff behave, how it talks to you, how it treats its staff, its recycling policy. It’s about knowing that when you go to John Lewis, you will get excellent service, but that if you fly Ryanair it will be cheap. Brand is why you’re surprised if you get shoddy quality from Boden, but not that surprised if you shop in a budget clothes shop and the clothes fall to bits after a few months. It’s about feeling trust in the NHS to look after you, but feeling ripped off by your utility company (there’s a brand challenge).  Trust is central to the value of a brand, and nowhere more so than in the public sector.

So what would happen if NDPBs adopted the consistent government identity? On the face of it, nothing. Taxpayers might shrug their shoulders and say ‘Oh, I never really knew that organisation was part of government, but clearly it is’. The organisation would remain the same independent advisor, it would just look different. But corporate identity is a very powerful expression of the brand, which is why they’re often conflated, and which is also why they must be consistent with one another.

So in this scenario, when it came to situations where those organisations were giving advice, would those being advised feel the same about it? If a regulator like the HSE exonerated a government department for a nasty accident on their premises, for example, would people feel that the inquiry had been carried out independently if both organisations looked, to all intents and purposes, exactly the same? Can one bit of central government truly, independently, regulate another? If an organisation is independent and at arm’s length from government and wants the taxpayers’ trust, it must look like it is independent and at arm’s length from government. Such is the power of a brand. An NDPB’s brand must convey those three tests that Francis Maude talked about – political impartiality, independence from government and technical expertise. If it carries the HM Government crest on all its communications channels, it’s going to have a tough time convincing anyone of those.